Opinion
2:21-cv-01334-RFB-BNW
12-12-2022
ROBERT COACHE, an Individual, Plaintiff, v. MARC DIGIACOMO, an individual and an employee of a government entity; COLIN HAYNES, an individual and an employee of a government entity; NATHAN CHIO, an individual and an employee of a government entity; and DOES 1-30, Defendants.
RALPH A. SCHWARTZ, PC ALPH A. SCHWARTZ EDWIN B. BROWN (Admitted Pro Hac Vice) BROWN CLARK LE AMES STEDMAN & CEVALLOS LLP Attorneys for Plaintiff, Robert Coache KAEMPFER CROWELL LYSSA S. ANDERSON KRISTOPHER J. KALKOWSKI Attorneys for Defendants, Colin Haynes, Lt. Nathan Chio STEVEN B. WOLFSON SCOTT DAVIS TIMOTHY ALLEN Attorneys for Marc DiGiacomo
RALPH A. SCHWARTZ, PC ALPH A. SCHWARTZ EDWIN B. BROWN (Admitted Pro Hac Vice) BROWN CLARK LE AMES STEDMAN & CEVALLOS LLP Attorneys for Plaintiff, Robert Coache
KAEMPFER CROWELL LYSSA S. ANDERSON KRISTOPHER J. KALKOWSKI Attorneys for Defendants, Colin Haynes, Lt. Nathan Chio
STEVEN B. WOLFSON SCOTT DAVIS TIMOTHY ALLEN Attorneys for Marc DiGiacomo
STIPULATION, REQUEST AND ORDER EXTENDING TIME TO FILE RESPONSES TO MOTIONS TO DISMISS [ECF NOS. 61 AND 62] (FIRST REQUEST)
RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE
Defendants, Colin Haynes and Lt. Nathan Chio (“LVMPD Defendants”), by and through their counsel Kaempfer Crowell, Defendant Marc DiGiacomo, by and through his counsel Deputy District Attorney, Scott Davis, and Plaintiff, Robert Coache, by and through his counsel Ralph Schwartz from Ralph Schwartz, PC and Edwin Brown from Brown Clark Le Ames Stedman & Cevallos LLP, hereby respectfully submit this Stipulation, Request and Order Extending Time to File Responses to Motions to Dismiss. This is the first request for an extension of time to respond to the Motions to Dismiss.
The LVMPD Defendants and DiGiacomo were served with Plaintiff's Amended Complaint on November 1, 2022. In response, DiGiacomo filed a Motion to Dismiss on November 29, 2022, [ECF No. 61] and the LVMPD Defendants filed a Motion to Dismiss on that same day also, [ECF No. 62]. The instant extension is requested as the Plaintiff's Counsel requires additional time to prepare responses to both Motions to Dismiss.
Upon agreement by and between all the parties hereto as set forth herein, the undersigned respectfully requests this Court grant an extension of time, up to and including December 23, 2022, for Plaintiff to file responses to the Motions to Dismiss, [ECF Nos. 61 and 62]. In addition, due to the intervening holidays, the LVMPD Defendants and Di Giacomo respectfully request that the time to file their respective reply briefs be extended up to and including January 13, 2023.
IT IS SO ORDERED:
ORDER
IT IS SO ORDERED.